Key facts
- The starter checklist replaced the P46 form and is used when a new employee has no P45.
- The employee chooses from Statement A, B, or C — each results in a different starter tax code.
- Statement A gives the standard 1257L tax code (cumulative), Statement B gives 1257L M1/W1, and Statement C gives BR.
- The employer must use the starter checklist information on the first FPS submitted for that employee.
- If the employee does not complete the checklist, the employer must use the 0T W1/M1 code (no free pay, non-cumulative).
What Is a Starter Checklist?
A starter checklist is a form that new employees complete when they join an employer and do not have a P45 from a previous job. It collects the information the employer needs to set up the employee on the payroll with the correct tax code.[1]
The checklist is needed in several common situations:
- It is the employee’s first job
- The employee has lost their P45 and cannot get a replacement
- The employee’s previous employer has not yet issued a P45
- The employee is coming from a period of self-employment, unemployment, or study
The Three Statements
The core of the starter checklist is three statements. The employee reads each one and ticks the statement that best describes their situation:[1]
| Statement | Description | Tax Code Applied |
|---|---|---|
| A | “This is my first job since last 6 April and I have not been receiving taxable Jobseeker’s Allowance, Employment and Support Allowance, taxable Incapacity Benefit, state pension, or occupational pension.” | 1257L (cumulative) |
| B | “This is not my first job since last 6 April and I do not receive a state pension or occupational pension. Since 6 April I have had another job but I do not have a P45.” | 1257L W1/M1 (non-cumulative) |
| C | “I have another job or receive a state pension or occupational pension.” | BR (basic rate, all pay taxed at 20%) |
Key point: Statement A gives the employee the full Personal Allowance on a cumulative basis — ideal for a genuine first job. Statement B gives the allowance but on a non-cumulative (Week 1/Month 1) basis, preventing over-refunding if the employee has already used some allowance elsewhere. Statement C assumes the allowance is used in another job and taxes all pay at the basic rate.
Student Loan Information
The starter checklist also asks whether the employee has a student loan or postgraduate loan, and if so, which plan type. This is important because the employer must start making deductions if the employee indicates they have a loan, even before HMRC sends a formal SL1 start notice.[2]
The plan types are:
- Plan 1: Loans taken out before September 2012 (or Scottish/NI loans before September 2023)
- Plan 2: Loans taken out after September 2012 (England and Wales)
- Plan 4: Scottish student loans from September 2023 onwards
- Plan 5: Loans from September 2023 onwards (England and Wales)
- Postgraduate Loan: Postgraduate Master’s or Doctoral loans
What the Employer Must Do
After receiving the completed starter checklist:[2]
- Apply the correct tax code based on the statement chosen (A, B, or C)
- Set up the payroll record with no previous pay or tax figures (year-to-date starts at zero)
- Note any student loan plan type and begin deductions from the first pay date
- Submit the first FPS with the starter declaration information (the statement used and the “new employee” indicator)
- Keep the checklist on file — HMRC may ask to see it during a compliance check
What If the Employee Does Not Complete the Checklist?
If a new employee fails to complete the starter checklist, the employer must use the 0T W1/M1 tax code. This gives no Personal Allowance and operates on a non-cumulative basis, meaning the employee will pay more tax than necessary until HMRC issues a correct code.[1]
Tip: Encourage new starters to complete the checklist on their first day. Delays mean the employer cannot set up the correct tax code, and the employee may be overtaxed. Most payroll software includes the starter checklist as part of the new employee setup process.
When a P45 Arrives After the Starter Checklist
If the employee later provides a P45 from their previous employer:
- If it is for the current tax year and has not yet been used — the employer can update the payroll with the P45 tax code and year-to-date figures, recalculating tax on a cumulative basis
- If it is from a previous tax year — it cannot be used; the year-to-date figures are not relevant
- If HMRC has already issued a P9 coding notice — use the HMRC code rather than the P45 code
Frequently Asked Questions
What if the new employee has lost their P45?
If the P45 is genuinely lost and cannot be obtained from the previous employer, the new employer should ask the employee to complete a starter checklist instead. The previous employer may be able to issue a duplicate P45, but there is no obligation to do so. In the meantime, the starter checklist ensures the new employee is taxed from their first payday.
Can the employer make the statement choice on behalf of the employee?
No. The employee must choose the statement themselves based on their personal circumstances. The employer should explain what each statement means but must not complete the form on the employee’s behalf or influence their choice. The employee is responsible for the accuracy of the information.
What happens after HMRC processes the starter information?
Once the employer submits the first FPS with the starter checklist information, HMRC will review the employee’s records and issue a proper tax code via a P9 coding notice. This may be the same as the starter code or it may be different. The employer must apply the new code from the date specified by HMRC, adjusting any over- or under-deducted tax cumulatively.
Does the starter checklist replace the P46?
Yes. The P46 form was abolished in April 2013 when RTI was introduced. The starter checklist serves the same purpose but is simpler. Unlike the P46, the starter checklist is not submitted to HMRC as a separate form — the information is included in the first FPS for the new employee.
Further Reading
- The P45 Process — how P45s work when employees leave and join
- How Tax Codes Work — understanding the tax codes assigned through the starter checklist
- Emergency Tax Codes — when starter codes result in emergency taxation
- Statutory Deductions (Tax, NI, Student Loan) — student loan deductions for new starters
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Sources
- New employee starter checklist — HMRC
- Running payroll: new employees — GOV.UK
- PAYE and payroll for employers — GOV.UK